Yosemite Lodge, Curry & E. Y. Valley Campground comments

October 11, 2003

Superintendent Tollefson:

Re: Friends of Yosemite Valley (FoYV) public comments on the 'Yosemite Lodge Area Redevelopment Plan Environmental Assessment' and the 'Curry Village and East Yosemite Valley Campground Improvements Project Environmental Assessment'

General Introduction:

The Friends of Yosemite Valley submit the following comment letter regarding the 'Yosemite Lodge Area Redevelopment Plan Environmental Assessment' and the 'Curry Village and East Yosemite Valley Campground Improvements Project Environmental Assessment' (EAs) under protest. A 30-day comment period is completely inadequate for the public to become informed of and to address the far-reaching and radical environmental and social changes proposed in these documents. The NPS is circumventing public process in fact, while it purports to conduct a valid compliance process. The midweek, in-park open houses were of no use to the vast majority in the public who work for a living and were thus unable to attend; in fact the public has had exactly 30 days to consider these proposals. Moreover, the in-park meetings underscore the instrumental and fraudulent conception which NPS holds of "public involvement" : since these meetings were intended to disclose evolving details of construction projects which have -- for years -- been decided in their scope and major elements, what exactly is the public being asked to say or do, beside stand mutely bye, serving NPS as the premise for project compliance?

The 30-day comment period directly and negatively affects our ability to comment on the current proposals The comment period should be extended 90 days so that the public has a chance to respond properly and in detail. In extending the comment period, NPS should avail itself of an opportunity to listen to informed comment, enriched by the outrage which these proposals merit.

The Friends of Yosemite Valley consider the proposals before us an affront to the public and an attack on the Valley environment for reasons we have previously stated. First, these plans call for the expansion of the lodging footprint in Yosemite Valley, accompanied by the expansion of asphalt and roadways. These are the direct environmental costs of planning for increased visitor use of the Valley environment. The plans represent a directed assault on the Yosemite Valley's natural and native cultural environment. We oppose this. Second, the plans will result in intensified visitation, exacerbating the new impacts to the Valley. We oppose this. Finally , the plans are discriminatory: they are an assault on equity of access for citizens and families of average economic means, who will not be able to afford the new, high-end accommodations. The current plans instead intend to maximize profits for the concessionaire. It is a matter of record that Friends of Yosemite Valley considers these proposals bad for the environment and socially discriminatory.

We have attempted to call NPS's attention to the obvious opportunities and changed environment which have become evident over the past years, but to no avail. Since 1997 hundreds of new lodging units have been built on the Park's boundaries and in the gateway communities surrounding Yosemite. This eliminates any rationale for the construction of new lodging in the park. But if NPS did not want to hear this from us, it should consider reading its own Policies, which make our same point and promulgate it as a rule to be followed; lodging should not be built in any park when the area communities are building it themselves. Here is a case of the park Service simply refusing to follow its own policy.

We previously stated our belief that the Yosemite Lodge area would be well served if the buildings were torn down, and the area then partly restored and partly turned into a campground. We think this is good public policy. Forty percent of Yosemite Valley's campsites were closed by the National Park Service in 1997, and they show no sign of returning. We have called for the creation of equitable access for the average family in Yosemite Valley. The establishment of camping on a formerly developed (hotel) site is one very good way to bring back equity and balance. Sadly, NPS is working diligently in the opposite direction.

It is outrageous that average citizens will be handed the multimillion dollar bill to pay for a sweeping round of new construction and degradation to their park's natural environment, even as many are newly denied access through higher pricing at new, upscale lodging facilities. The multinational Delaware North Company, meanwhile, adds to its profits.

General Objections

1) Scoping is required when a proposal or project may entail controversy, and that is certainly the case here. Scoping should cause the agency to reconsider what it is proposing, and to change its direction. This should have applied to the documents before us, but the documents before us demonstrate that NPS has refused to change its long standing scheme to expand and intensify lodging infrastructure in Yosemite Valley. It is a matter of record that the public rejected the proposals for expanded, upscale lodging facilities in 1992; this was followed by litigation opposing the Lodge proposal in 1998 (that proposal was virtually identical in scope to the proposals before us). Next, a flood of negative comments regarding lodging proposals arose under both scoping and final comments for the Valley Plan. NPS may not simply ignore more than a decade of opposition, including legal action, against the main elements of its lodging proposals. To do so, as the present documents do, merely indicates that NPS wrongly considers scoping an exercise designed to insulate proposals from fundamental change. If this were not the thinking of NPS, how could these projects have ploughed forward unchanged since 1998?

2) Both the Yosemite Lodge and the Curry Village EA's (Environmental Assessments) should be put out to the public as Draft Environmental Impact Statements. The scope and extent of these two development proposals indicate significant negative environmental impacts which require EIS's.

3) Neither plan is protective of the Outstandingly Remarkable Values of the Merced River. In fact both plans of these related plans will lead to direct degradation of the Merced River's ORVs. It is the NPS's duty under law to protect and enhance the Merced River's ORVs. The present plans degrade these values. Consequently, we oppose these plans.

4) NPS planning in the current documents builds towards a year-round , winterized pattern of visitation at higher, more intense levels. The Yosemite Valley Plan threw out the GMP use limits, and the present documents illustrates that the result is unfettered planning and construction for higher levels of use. (FoYV previously pointed this out (IV-215) ). NPS has never established any capacity limits for Yosemite Valley which would protect the ORVs of the Merced River. NPS is thus promoting the current projects in complete contravention of its duty to deal with capacity as an instrument to protect the Merced River, its values, or the Valley environment more generally. The two current plans accommodate and encourage new, higher visitation levels; in fact they would accommodate the 1980 Yosemite General Management Plan (GMP) daily limit of 18,241 for each day of the year. Currently such numbers are only reached in peak season. And as stated on Page IV-215: "Visitation in excess of 18,241.. would be served by regional transit or other alternative forms of transportation." In effect, any attempt at capacity limits has been eliminated. These constitute further reasons for our opposition to the current plans.

Further Objections to the Yosemite Lodge EA:

5) A new "Northside Drive" road is proposed to be constructed within feet of the Merced River. We adamantly oppose this. Construction of such a road will degrade the river and its Outstandingly Remarkable Values. New impacts from runoff, noise, the destruction of riparian forest and near-meadow forest, as well as impacts to sensitive species will occur. We oppose the construction of this road.

7) The natural function of the Merced River, as a living, biological system will be impaired. The Merced should not be subjected to further human impacts.

8) The floodplain will be newly altered. The Merced River's hydrologic processes will be negatively impacted. We oppose these alterations.

9) Wildlife corridors will be disrupted. We oppose the Plan' proposed new impacts to wildlife corridors.

10) the Merced River's riparian zone will be negatively impacted. We oppose this.

11) The current opportunity for a quiet river experience will be destroyed. We oppose the project for this reason as well.

12) The project completely ignores the existence of the river's backwater area -- a wetlands which will be degraded or destroyed, by the proposed new location for the new Northside Drive. This is, in part, a revelation of the ineffectual nature of the Merced River Plan's alleged "protection " mechanism, the River Protection Overlay. Since the road was laid out and the entire complex planned before NPS had any notion of protecting the Merced, the near intersection of the road and the River's back channel is an example of illegal, destructive priorities encoded in the plan. We oppose this blind and destructive road construction for this reason.

13) The new Northside Drive would, moreover, be bulldozed through significant sections of a currently undisturbed ancient black oak woodland area. We oppose the action for this reason as well.

14) The proposed new bridge will destroy or degrade the Native American traditional mushroom gathering area, and other Native American cultural areas which continue to be used today. We oppose these destructive acts proposed in this plan .

15) Nearly 1100 trees will be logged (of which only 24 are considered hazardous). Such deforestation will greatly impair the biological function of this area. We oppose the cutting of those trees.

16) This proposal will create new disturbances to the traces of the main Native American archeological village site of "Koom-i-ne". The entire Lodge area is an archaeologic site associated with this village, and should be preserved and respected. Direct descendants of this village are alive today. It is their ancestors home and grave sites which this project will disturb. We strongly oppose the project for this reason as well.

Camp 4:

17) We think Camp 4, in a form similar to the present with low amenity walk-in camping, is a good example for the park to follow. For this reason, we oppose what is currently proposed for it. We are particularly dismayed by the emphasis on new structures associated with the campground. We oppose the addition of new buildings.

18) Camp 4 does not need a "cooking pavilion". It makes sense for people to congregate, but we do not favor a structure to facilitate it.

19) A "climbing display building" is not needed in the Camp 4 campground. It would "feature interpretive displays and presentations on the climbing history of Yosemite National Park and would incorporate an interior lounge area for park visitors to congregate while viewing the displays"? We object to this; these displays or buildings for gathering places should be located in existing buildings, or in a public lounge. We do think that indoor, public lounge or something like this could be a real benefit in a Valley environment which emphasized camping, since inclement weather will always come. Such buildings are already in existence; NPS should propose ways to promote public, noncommercial shared use of them. New buildings in Camp 4 are the wrong idea.

20) Camp 4 should not be expanded north of the existing Northside Dr. disrupting and for the most part destroying an oak woodland area which has been undergoing restoration since 1969 (IV-70. Yosemite's native Americans also lived in the area until very recently, but were harshly evicted by the NPS. At that time, the NPS stated that that area from then on would be protected as an environmental restoration area. This area is already a narrow area by the Valley wall and the rim trail and a corridor used by wildlife. Putting a new campground in that area is a significant and unnecessary new impact to an area currently enjoyed for walking and bouldering.

Northside Drive :

21) The proposal to turn the portion of Northside Dr. from west of Camp 4 into a walking/biking path, rather than its role as the one way automobile/bus exit road in the existing longtime loop would create a greater risk to visitors. This portion of Northside Dr. contains many hazardous rockfall and boulder bounce zones. It would be more hazardous for visitors to be exposed on foot or bike moving slowly along this route than in an automobile or bus. This route is closed due to rockfall not infrequently and Southside Dr. is closed in winter, not infrequently from hazardous slippery conditions. The two way system works better than what is proposed. The new proposal makes new and potentially more problematic and hazardous situations. We oppose this

Southside Drive:

22) Hundreds, if not thousands of additional trees including ancient black oaks would be cut down to widen Southside Drive -- which would be in the Merced River Wild and Scenic corridor. Many of the most beautiful flowering dogwoods which line Southside Drive in the spring would be bulldozed away. The entire structure of the riparian forest along Southside Drive would be dramatically altered as a result of the immediate proposal to close Northside Drive and widen Southside Drive. We oppose this

Further Objections: Curry Village EA:

23) FoYV objects to the East Yosemite Valley Campground Improvements Project EA for the following and other reasons. In general, the overwhelmingly large and intense new development will create Curry CITY. This overblown, massive project runs absolutely counter to any reasonable environmental or social goal for the Valley, and defies common sense. To name some but not all of our objections:

24) We object to the proposed new 2,000 to 4000 sq. ft. campground registration structure

25) We object to the proposed new 3,000 to 4000 square ft. Mountain shop

26) We object to the proposed new 8000 square foot, expanded Grocery store

27) We object to the proposed new 3,000 to 4,000 square foot employee cafeteria

28) We object to the proposed new 6,000 to 8,000 square foot housekeeping / maintenance building

29) We object to the proposed new 1500 to 1800 square ft Curry village registration building

30) We object to a new 1,500 to 1,800 square foot fire station / security office and support building

31) We object to the proposed new 1,500 to 1,800 square foot ice rink retail building

32) We object to the proposed new 1,600 to 2,000 square feet raft / bicycle rental building

33) We object to the proposed new 460-seat amphitheater at Clark's Bridge

34) We object to the proposed new RV dump station

35) The above objections notwithstanding, we believe NPS should not intensify use for some of the above areas as they are potential rockfall and boulder bounce areas.

36) We object in the strongest terms to this plan which will result in the loss of more than 1300 trees be cut down in the Curry Village area, not including the employee housing area.

37) We further object to the proposal to relocate Curry Village Road, and the destructive environmental effects, similar in all respects to those mentioned regarding Southside Drive in (22) above.

38) A further problem arises from the removal of Day Visitor Parking at Curry Orchard. We object, inasmuch as this change is being made in concert with proposals which would effectively create mandatory use of mass transit. But the use of mass transit as proposed is a mechanism to facilitate unlimited usage of Yosemite Valley. We therefore oppose it. The current plan predicts upwards of 362 inbound buses daily. That would mean approximately one bus would be arriving or leaving every 2 minutes. (IV-219). We believe this is regressive, and will harm the Valley environment and visitor experience. ( Please see our comments on the need for user capacity under "General Introduction" and number "4" above).

Sincerely,

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